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«FINAL AUDIT REPORT ED-OIG/A07L0001 February 2014 Our mission is to promote the U.S. Department of Education efficiency, effectiveness, and Office of ...»

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This policy was developed in response to the new regulatory definition of attendance at an academically related activity (34 C.F.R. § 668.22(l)(7)), effective July 1, 2011. Valencia stated that the audit period was before the time for which enhanced requirements for documenting online class attendance was required.

Determination of Attendance Affects Compliance With the Title IV Requirements We identified attendance issues that affected Valencia’s compliance with the Title IV requirements in four areas: (1) treatment of Title IV funds when a student withdraws, (2) treatment of Title IV funds when a student does not begin attendance, (3) confirmation of eligibility at the time of disbursement, and (4) recalculation of the Pell award.

Treatment of Title IV Funds When a Student Withdraws Of the 50 students in our sample, 14 withdrew during a payment period. Valencia performed return of Title IV aid calculations for all 14 students. Valencia used an unsupported last date of attendance in the return of Title IV aid calculations for three students, resulting in it returning $514 less than it should have for two students. We concluded that the third student attended enough of the payment period to earn 100 percent of the Title IV funds disbursed for the payment period.

Valencia stated that it considered a student’s last date of attendance to be the date the registrar or faculty member initiated the withdrawal or the date the student officially withdrew. For a registrar-or faculty-member-initiated withdrawal during award year 2010–2011, Valencia agreed that it did not always use the student’s last date of attendance at an academically related activity as the student’s last date of attendance. Valencia stated that, during the audit period, logging in to an online course was acceptable as an activity supporting attendance during the first week of the course; however, it since has implemented new procedures. The new procedures were effective July 1, 2011, and Valencia stated that the procedures reflected the new regulatory definition of attendance at an academically related activity (34 C.F.R. § 668.22 (l)(7), effective July 1, 2011).

We disagree with Valencia’s position that a student’s logging in to an online course was sufficient evidence of academic attendance during our audit period. Even before July 1, 2011, the regulations required that the activity supporting attendance be academically related. We also reviewed Valencia’s new procedures. As currently written, the new procedures are applicable only for the first week of the course when faculty members must determine whether the students began attending their courses.

Treatment of Title IV Funds When a Student Does Not Begin Attending Classes Of the 50 students in our sample, Valencia did not return $10,303 in Title IV funds that it credited to the accounts of or disbursed directly to 7 students without evidence of the students’ attendance in academically related activities during the payment period.

Valencia stated that its procedures were that Title IV funds would be disbursed during the fourth week of each semester, and faculty members were required to report students who did not attend within the first week of the course as “no shows.” Valencia would not disburse Title IV funds until it verified student attendance. However, Valencia acknowledged that, during the audit Final Audit Report ED-OIG/A07L0001 Page 63 of 83 period, it did not define attendance as participation only at an academically related activity. As stated above, during the audit period, Valencia’s definition of attendance for an online course was any activity recorded in the online learning management system. Valencia stated that, effective August 2011, it implemented new procedures that reflect the regulatory definition of attendance at an academically related activity.

Confirmation of Eligibility at the Time of Disbursement The records for 19 of the 50 students in our sample indicated that the students received Title IV disbursements after the start of the payment period without evidence of the students’ attendance in an academically related activity before the disbursements.

Valencia stated that 16 of the 19 students participated in an academically related activity or had logged in to their courses. For two students, Valencia said the students did not have attendance and for one student, Valencia did not have information from the faculty member on the student’s attendance.

We disagree with Valencia’s position. For Title IV funds disbursed during the payment period, Valencia is required to confirm that each student engaged in academically related activity before the disbursement. Simply logging in to a course is not an academically related activity, and Valencia’s online learning management system did not show evidence that any of the 19 students attended academically related activities as required by 34 C.F.R. § 668.22(c)(3) before the disbursements.

Recalculation of Pell Awards Of the 50 students in our sample, Valencia’s online learning management system or other records for 13 students indicated a change in enrollment status based on the students’ lack of attendance at academically related activities in one or more of their courses. The enrollment status changes for 10 of the 13 students had an effect on their Pell eligibility. However, Valencia did not properly recalculate the Pell awards for those 10 students. As a result, Valencia awarded $6,264 more than it should have awarded to the 10 students.





Valencia obtained comments from faculty members for 9 of the 10 students. However, those comments did not cause us to change our position. After we reviewed the comments, we concluded that the faculty members did not always use academically related activity as evidence of attendance. For example, one faculty member used a student’s logging in to the course as evidence of attendance. Another faculty member used the date the faculty member informed the student that the student would be dropped from the course as evidence of attendance.

Final Audit Report ED-OIG/A07L0001 Page 64 of 83 Appendix G: Liberty University Private nonprofit school Liberty University was founded in 1971 and is located in Lynchburg, Virginia. Liberty University is accredited by the Commission on Colleges of the Southern Association of Colleges and Schools. Liberty University offers more than 230 programs of study, including more than 45 degree programs through distance education. During award year 2010-2011, Liberty University disbursed more than $430 million in Title IV funds to about 45,000 students, including about 36,000 students who were enrolled solely in distance education courses.

Cost of attendance Liberty University’s cost of attendance budget includes tuition and fees and allowances for room and board, books and supplies, transportation, personal computer, dependent care, and loan expenses. For distance education students, Liberty University created a separate cost of attendance budget that included the same cost categories as the cost of attendance budget for traditional students; however, some of the amounts varied.

Billings and Disbursements Liberty University is a term-based school, operating on a semester system. It established the semester as its payment period for Title IV purposes. Liberty University offered a fall and spring semester that were 17 weeks and a summer semester that was 14 weeks. The semesters were divided into 8-week sessions. The fall and spring semesters had three sessions and the summer semester had two sessions. Each session had a different start and end date.

Liberty University charged tuition and fees by session.

Liberty University also disbursed Title IV funds by session. It disbursed Pell funds the first day of the session and loan funds 17 days after the start of the session in which the student reached half-time status. The Title IV disbursements were prorated throughout the payment period by session. For example, if a student enrolled in 3 credit hours in the first session and 3 credit hours in the second session, he or she would receive half of the Pell award for the semester in the first session and the remaining Pell award for the semester in the second session. The student would receive the loan funds 17 days after the start of the session in which the student reached half-time status of 6 credit hours. Liberty University’s higher education software ran eligibility checks on distance education students before Title IV funds were disbursed.

Attendance and Withdrawal Policies Liberty University defined academic attendance for distance education students as any submission to its online learning management system within the enrollment dates of the course or any student-initiated communication with his or her faculty member regarding an academic subject or course materials. Examples of activities that Liberty University accepted as evidence of attendance included the course requirements checklist, introductory discussion board postings, student group activities, and academic advising and counseling. Evidence of academic attendance was maintained in either the online learning management system or outside the online learning management system.

Liberty University also required distance education students to establish attendance during the first week of class. Students who failed to submit an assignment, such as Liberty University’s course requirements checklist, an examination, written paper, discussion board post, or other Final Audit Report ED-OIG/A07L0001 Page 65 of 83 academic event, during the first week were removed from the class roster. If a distance education student attended the first week of a course but then had 21 consecutive days without attendance, the student would receive a grade of FN, which indicated failure for not attending.

Faculty members were responsible for identifying students who had 21 consecutive days without attendance and recording an FN grade.

Liberty University was not required to take attendance. However, for students who unofficially withdrew, Liberty University used the last date of attendance as the withdrawal date for return of Title IV aid calculations.

Determination of Attendance Affects Compliance With the Title IV Requirements We identified attendance issues that affected Liberty University’s compliance with the Title IV requirements in three areas: (1) treatment of Title IV funds when a student does not begin attendance, (2) confirmation of eligibility at the time of disbursement, and (3) recalculation of the Pell award.

Liberty University disagreed with the OIG’s interpretation of what activities could be used as evidence of academic attendance (see “Methodology for Reviewing Student Records” in Appendix B). Liberty University stated that the OIG’s insertion of its own legally unsupported opinion as to what activities should be treated as evidence of academically related activity raised concerns that the OIG was asserting its influence over the school’s curriculum. Such influence is in violation of the prohibition against Federal control of education.

We disagree with Liberty University’s position. We based our conclusions on the regulations in effect during the audit period. Those regulations required activity supporting attendance to be academically related. We also disagree that our interpretation of the regulation interferes with Liberty University’s curriculum decisions. Our interpretation is not an attempt to control curriculum. We limited our work to applying the regulations in effect during the audit period and concluding whether the school maintained sufficient evidence of academic attendance.

Treatment of Title IV Funds When a Student Does Not Begin Attending Classes Of the 50 students in our sample, Liberty University did not return $4,358 in Title IV funds that it credited to the accounts of or disbursed directly to three students without evidence of the students’ attendance in academically related activities during the payment period. The three students’ only activity in the payment period was completing Liberty University’s course requirements checklist. Completion of the course requirements checklist showed only that the student had (1) read the syllabus; (2) read the student expectation documents explaining the meaning and policies regarding plagiarism, attendance, FN grade (nonattendance) policy, and honor code; and (3) submitted a quiz demonstrating his or her completion of items (1) and (2).

We did not consider Liberty University’s course requirements checklist to be evidence that the student attended an academically related activity in the course.

Liberty University disagreed and stated that it considered submission of the course requirements checklist or the submission of discussion posts to introduce oneself to classmates to meet the regulatory definition of an academically related activity that was in effect during the audit period. Liberty University believed that the OIG applied regulations governing the determination of attendance that were not in effect during the audit period. Specifically, Final Audit Report ED-OIG/A07L0001 Page 66 of 83 Liberty University believed that the OIG applied the definition of attendance in 34 C.F.R.

§ 668.22(l)(7)(i), which did not become effective until July 1, 2011.

We disagree with Liberty University’s position. We did not consider the course requirements checklist or the submission of discussion posts to introduce oneself to classmates to be an academically related activity because the activities covered by the checklist or the discussion posts are not related to the subject matter of the course. Even before July 1, 2011, the regulations required the activity to be academically related, not administratively related. We considered the activities used by Liberty to justify disbursements and retention of Title IV funds to be administratively related.

Confirmation of Eligibility at Time of Disbursement The records for 1 of the 50 students in our sample indicated that the student received a Title IV disbursement after the start of the payment period without evidence of the student’s attendance in academically related activities. Liberty University disbursed $268 of Title IV funds to the student. The student’s only activity in the payment period was completing the course requirements checklist.

Liberty’s position and our disagreement are the same as noted in the “Treatment of Title IV Funds When a Student Does Not Begin Attending Classes” issue.



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